- 20 -
1988) (quoting Ebben v. Commissioner, 783 F.2d 906, 909 (9th Cir.
1986), affg. in part and revg. in part T.C. Memo. 1983-200),
affg. in part and revg. in part on another ground T.C. Memo.
1986-318. We are not bound by the formulae and opinions prof-
fered by expert witnesses, especially when they are contrary to
our judgment. See Silverman v. Commissioner, 538 F.2d 927, 933
(2d Cir. 1976), affg. T.C. Memo. 1974-285; Estate of Davis v.
Commissioner, supra. Instead, we may reach a determination of
value based on our own examination of the evidence in the record.
See Lukens v. Commissioner, 945 F.2d 92, 96 (5th Cir. 1991)
(citing Silverman v. Commissioner, supra at 933), affg. Ames v.
Commissioner, T.C. Memo. 1990-87; Estate of Davis v. Commis-
sioner, supra. The persuasiveness of an expert's opinion depends
largely upon the disclosed facts on which it is based. See Tripp
v. Commissioner, 337 F.2d 432, 434 (7th Cir. 1964), affg. T.C.
Memo. 1963-244; Estate of Davis v. Commissioner, supra. Where
experts offer divergent estimates of fair market value, we shall
decide what weight to give those estimates by examining the
factors used by those experts to arrive at their conclusions.
See Estate of Davis v. Commissioner, supra; Casey v. Commis-
sioner, 38 T.C. 357, 381 (1962). While we may accept the opinion
of an expert in its entirety, see Estate of Davis v. Commis-
sioner, supra; Buffalo Tool & Die Manufacturing Co. v. Commis-
sioner, 74 T.C. 441, 452 (1980), we may be selective in the use
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